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Response to DRMS Adequacy Review — Cotter SR -13A Mine Reclamation Plan Amendment <br />The location for the Entrada/Navajo Sandstone well is well permit #29748 — M, and <br />can be found in Appendix I — Supporting Documents under the "well logs" tab. <br />13. Addressing Rule 6.4.21 (9) (a) — Please address this rule. <br />Presently there is no use for groundwater near the SR -13A site. The ground water <br />down gradient of the site is too deep to be economical. Please see the discussion on <br />pages T -12 and T -13 of the EPP. <br />14. Addressing Rule 6.4.21 (I1)(a)- Please address this rule. The Division considers the Dolores <br />River to be a receiving stream within two miles and down gradient from the affected lands. <br />There are no current uses for the surface water down gradient from the site. <br />Potential future uses include drinking water and livestock water but these are <br />unlikely because the area is sparsely populated and there is higher quality <br />groundwater at Slick Rock. (Note that Slick Rock is up river from the SR -13A site <br />and the groundwater at Slick Rock is up gradient from the site. Thus, the <br />groundwater is shallow at Slick Rock but dips steeply to the northeast toward the <br />SR -13A site rendering the groundwater downgradient of the site too deep to be <br />economically viable.) <br />15. Addressing Rule 6.4.21 (12) — On page T -16, the EPP states that if water is encountered <br />during mining, and chemical analysis determines that uranium related constituents are above <br />regulatory guidelines, then a monitoring well will be installed If groundwater is <br />encountered during mining, a monitoring well shall be installed and a monitoring plan shall <br />be established in accordance with this rule, regardless of the results of the chemical analysis. <br />Please commit to this. <br />Cotter commits to installing a monitoring well and establishing a monitoring plan in <br />the case that any water is encountered during mining. <br />16. Addressing Rule 6.4.21(14) — SPLP tests were conducted in order to characterize the waste <br />rock generated at this site. According to this rule, the ore must also be characterized <br />Please submit to the Division, a geochemical evaluation of the ore to be mined <br />Alternatively, if ore samples are not available at this time, commit to submitting this <br />information to the Division, for review and approval, prior to any stockpiling on the surface. <br />Prior to ore being stockpiled on the surface, Cotter will submit to DRMS for its <br />review and approval a geochemical evaluation of the ore to be mined. <br />17. Addressing Rule 6.4.21 (16) — On page T -24, the EPP states that design and implementation <br />of the Drainage Design Plan will be overseen by a registered professional engineer. Please <br />commit to submitting an "As-Built-Certification" to the Division following construction. <br />4 <br />